Klausner v. Lucas Film Entertainment Company LTD et al

Filing 34

ORDER re 33 Granting Stipulation Changing Expert Discovery Deadlines. Signed by Judge Claudia Wilken on 5/27/2010. (ndr, COURT STAFF) (Filed on 5/27/2010)

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ROBERT M. LIEBER, ESQ. SBN: 039976 NAKI M. IRVIN, ESQ. SBN: 094120 MARGOLIS & TISMAN LLP 601 Montgomery Street, Suite 2030 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] Attorneys for Defendant INDUSTRIAL LIGHT AND MAGIC, a division of LUCASFILM ENTERTAINMENT COMPANY LTD. ANDREW F. PIERCE, ESQ. SBN: 101889 STACY NORTH, ESQ. SBN: 219034 PIERCE & SHEARER LLP 2483 E. Bayshore Road, Suite 202 Palo Alto, CA 94303 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] Attorneys for Plaintiff DREW KLAUSNER UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION

DREW KLAUSNER; Plaintiff, v. INDUSTRIAL LIGHT AND MAGIC, a division of LUCASFILM ENTERTAINMENT COMPANY LTD. and DOES 1 through 25, inclusive, Defendants.

Case No. CV 09-03502-CW STIPULATED REQUEST FOR ORDER CHANGING EXPERT DISCOVERY DEADLINES & [PROPOSED] ORDER; DECLARATION OF NAKI M. IRVIN [Civ. L.R. 6-2]

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

Action Filed: July 30, 2009 Trial Date: April 11, 2011

Printed on Recycled Paper

STIPULATED REQUEST FOR ORDER CHANGING EXPERT DISCOVERY DEADLINES

Case No. CV 09-03502-CW

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

STIPULATION OF THE PARTIES WHEREAS, pursuant to the Court's Case Management Order dated December 1, 2009 (docket no. 21), the deadline to disclose the identities and reports of expert witnesses in this case is June 18, 2010, and the deadline to complete expert discovery is July 19, 2010; WHEREAS, the trial of this action is not scheduled to begin until April 11, 2011; WHEREAS, fact discovery is not scheduled to be completed until June 18, 2010; WHEREAS, the parties' expert witnesses cannot prepare complete reports of all their opinions in this matter until after they have had an opportunity to review fact discovery; WHEREAS, there have been no previous time modifications in this case; WHEREAS, continuing the expert discovery deadlines would not delay the trial date or otherwise affect the schedule for this case; THEREFORE, pursuant to Civil Local Rule 6-2, the parties to this action, by and through their counsel of record, do HEREBY STIPULATE AND REQUEST THE COURT TO ORDER as follows: (1) The deadline to disclose the identities and reports of expert witnesses is extended from June 18, 2010 to August 31, 2010; and (2) The deadline to complete expert discovery is extended from July 19, 2010 to October 1, 2010. // // // // // // // //

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Printed on Recycled Paper

STIPULATED REQUEST FOR ORDER CHANGING EXPERT DISCOVERY DEADLINES

Case No. CV 09-03502-CW

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

IT IS SO STIPULATED. DATED: May 19, 2010 MARGOLIS & TISMAN LLP By: /s/ Naki M. Irvin NAKI M. IRVIN Attorneys for Defendant INDUSTRIAL LIGHT AND MAGIC, a division of LUCASFILM ENTERTAINMENT COMPANY LTD. DATED: May 19, 2010 PIERCE & SHEARER LLP By: /s/ Stacy North STACY NORTH Attorneys for Plaintiff DREW KLAUSNER

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED. (1) The deadline to disclose the identities and reports of expert witnesses is extended from June 18, 2010 to August 31, 2010; and (2) The deadline to complete expert discovery is extended from July 19, 2010 to October 1, 2010. 5/27/2010 DATED: _______________ __________________________________ HON. CLAUDIA WILKEN United States District Court Judge

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Printed on Recycled Paper

STIPULATED REQUEST FOR ORDER CHANGING EXPERT DISCOVERY DEADLINES

Case No. CV 09-03502-CW

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MARGOLIS & TISMAN LLP
ATTORNEYS AT LAW -------------------601 MONTGOMERY STREET SUITE 2030 SAN FRANCISCO CALIFORNIA 94111

DECLARATION OF NAKI M. IRVIN I, Naki M. Irvin, declare as follows: 1. 1. I have personal knowledge of the facts set forth below. I am a partner with Margolis & Tisman LLP, which is counsel of record in this

action for Defendant Industrial Light & Magic, a division of Lucasfilm Entertainment Company Ltd. ("Defendant"). Pursuant to Civil Local Rule 6-2(a), I am making this declaration to

accompany the parties' stipulated request for an order changing the expert discovery deadlines in this case. 2. The reason for the requested enlargement of time is that the expert witnesses cannot

prepare complete reports of all their opinions in this matter until after they have had an opportunity to review fact discovery. Pursuant to the Court's December 1, 2009 Case Management Order (docket no. 21), fact discovery is not scheduled to be completed until June 18, 2010. 3. 4. There have been no prior time modifications in this case. The requested time modification will not delay the trial, which is not scheduled to

begin until April 11, 2010, or otherwise affect the schedule for this case. I declare, under penalty of perjury, under the laws of the United States, that the foregoing is true and correct, and that this declaration was executed this 19th day of May, 2010, at San Francisco, California. /s/ Naki M. Irvin NAKI M. IRVIN

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Printed on Recycled Paper

STIPULATED REQUEST FOR ORDER CHANGING EXPERT DISCOVERY DEADLINES

Case No. CV 09-03502-CW